SEC Comment Letter for Seagate Technology Holdings plc (STX) (CIK 0001137789) (STX) — Jan 9, 2013
Seagate Technology Holdings plc (STX) (CIK 0001137789)
Date: Jan. 9, 2013 · CIK: 0001137789 · Accession: 0000000000-13-001381
AI Filing Summary & Sentiment
Referenced dates: December 12, 2012, November 9, 2012
Letter
January 9, 2013 Via E -mail Patrick J. O’Malley Chief Financial Officer Seagate Technology plc 10200 S. De Anza Blvd. Cupertino, CA 95014
Re: Seagate Technology plc Form 10 -K for the Fiscal Year Ended June 29, 2012 Filed August 9, 2012 File No. 001 -31560
Dear Mr. O’Malley :
We have reviewed your letter dated December 12, 2012 in connection with the above - referenced filing an d have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the req uested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments. Unless otherwise noted , where prior comments are referred to they refer to our letter dated November 9, 2012 .
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources, page 54 1. We have reviewed your response to prior comment 3 and your proposed disclosure. While we note that you intend to permanently reinvest such funds outside of Ireland and that these funds are no t considered a main source of liquidity for funding Irish operations, we continue to believe you should consider providing enhanced liquidity to disclose the amount of cash held by non -Irish subsidiaries that would be subject to the potential tax impact as sociated with the repatriation of undistributed earnings. As part of your response, please quantify the amount of cash and cash equivalents held in foreign subsidiaries that you intend to permanently reinvest earnings.
Patrick J. O’Malley Seagate Technology plc January 9, 2013 Page 2
Please contact Ryan Rohn, Staff Ac countant, at (202) 551 -3739, or Christine Davis, Assistant Chief Accountant, at (202) 551 -3408, if you have any question regarding accounting or financial statements matters. If you require further assistance, do not hesitate to contact me at (202) 551 -3730.
Sincerely,
/s/ Stephen Krikorian
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January 9, 2013 Via E -mail Patrick J. O’Malley Chief Financial Officer Seagate Technology plc 10200 S. De Anza Blvd. Cupertino, CA 95014 Re: Seagate Technology plc Form 10 -K for the Fiscal Year Ended June 29, 2012 Filed August 9, 2012 File No. 001 -31560 Dear Mr. O’Malley : We have reviewed your letter dated December 12, 2012 in connection with the above - referenced filing an d have the following comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by amending your filing, by providing the requested information, or by advising us when you will provide the req uested response. If you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your filing and the information you provide in response to this comment, we may have additional comments. Unless otherwise noted , where prior comments are referred to they refer to our letter dated November 9, 2012 . Management’s Discussion and Analysis of Financial Condition and Results of Operations Liquidity and Capital Resources, page 54 1. We have reviewed your response to prior comment 3 and your proposed disclosure. While we note that you intend to permanently reinvest such funds outside of Ireland and that these funds are no t considered a main source of liquidity for funding Irish operations, we continue to believe you should consider providing enhanced liquidity to disclose the amount of cash held by non -Irish subsidiaries that would be subject to the potential tax impact as sociated with the repatriation of undistributed earnings. As part of your response, please quantify the amount of cash and cash equivalents held in foreign subsidiaries that you intend to permanently reinvest earnings. Patrick J. O’Malley Seagate Technology plc January 9, 2013 Page 2 Please contact Ryan Rohn, Staff Ac countant, at (202) 551 -3739, or Christine Davis, Assistant Chief Accountant, at (202) 551 -3408, if you have any question regarding accounting or financial statements matters. If you require further assistance, do not hesitate to contact me at (202) 551 -3730. Sincerely, /s/ Stephen Krikorian Stephen Krikorian Accounting Branch Chief cc: Via E -Mail Kenneth M. Massaroni, Esq, Stephen J. Luczo , CEO